Data Processing Addendum
1. Subject matter
We process personal data on your behalf solely to deliver the SMS and voice services under the Terms, including message transmission, delivery receipts, and regulatory compliance (e.g., A2P 10DLC registration).
2. Subprocessors
We use the following subprocessors:
- Telnyx LLC (USA) — telephony.
- Twilio Inc. (USA) — telephony.
- SignalWire Inc. (USA) — telephony.
- Stripe, Inc. (USA) — payment processing.
- Railway Corp. (USA) — hosting.
- The Campaign Registry, Inc. (USA) — A2P brand / campaign registration.
We will notify you by email at least 30 days before adding a new subprocessor. You may object and, if we cannot accommodate, terminate the affected service.
3. Security measures
TLS in transit, scrypt password hashing, least-privilege access, quarterly access reviews, and documented incident response. We will notify you of a confirmed personal data breach within 72 hours of becoming aware.
4. International transfers
Where personal data is transferred from the EEA or UK to the US, we rely on the applicable Standard Contractual Clauses (EU 2021/914) and UK International Data Transfer Addendum, which are incorporated by reference.
5. Deletion
On termination of the Terms, we will delete or return all personal data within 90 days, except where retention is required by law (telecom and tax record-keeping).
6. Contact
To request a counter-signed DPA on your paper, email legal@your2ndline.com.